Tax

Overview

The Tax practice is small, technical, and integrated with the rest of the firm. Partnership taxation is the center of the work: LLC and limited-partnership structures for operating businesses, joint ventures, real-estate holding entities, and private investment vehicles. Most of what the group does supports Corporate and Real Estate transactions — structuring the vehicle, drafting the allocation and distribution provisions, and advising on the tax consequences at exit. The practice is chaired by Flannery O'Neill, who holds an LL.M. in Taxation from NYU.

IRS controversy work covers the full path from examination through administrative appeal to Tax Court or refund litigation. We handle partnership examinations under the BBA centralized audit regime, international-information-reporting penalty defenses, and Office of Professional Responsibility matters. When a case calls for trial counsel, the group coordinates with the firm's Litigation team, but the tax merits are handled within Tax.

Connecticut state and local tax is a meaningful slice of the practice. The Department of Revenue Services remains aggressive on residency and nexus examinations, on the Pass-Through Entity Tax (PET) compliance that Connecticut enacted in 2018 and has amended several times since, and on the sales and use tax treatment of software and digital services. O'Neill has represented clients in DRS audits, in formal administrative protests before the department's Appellate Division, and in appeals to the Connecticut Tax Session of Superior Court.

Pass-through entity tax planning deserves a paragraph of its own because it has become the dominant Connecticut state tax planning item for mid-market businesses. Connecticut's PET election, recent statutory revisions to the credit mechanism, and the interaction with the federal SALT-cap workaround consume a disproportionate share of the group's time. We advise multi-state partnerships on the PET versus non-election analysis, on nonresident partner composite returns, and on the credit limitations for Connecticut-resident partners receiving credits from other jurisdictions.

Wally Reynolds, a Junior Associate with a UConn LL.M. in Taxation and a Connecticut CPA credential, handles much of the state-and-local audit defense work and IRS examination support. Paralegal Karen Hoffman, who came to the firm from a regional CPA practice, anchors documentation and filings on the group's audit docket.

We do not prepare tax returns. Clients engage their accountants for that. What we do is advise on the structural questions, defend the examinations, and argue the disputes — the three places where tax law actually intersects with the firm's litigation and transactional practices.